Reckitt Benckiser (I.) Pvt. Ltd. v Dy. CIT (2020) 81 ITR 577 (Kol) (Trib)

S.92C: : Transfer pricing – Arm’s length price – Royalty -Paid for basket of services — Adjustment is held to be not justified -Advertising, marketing and promotion of sales expenses —No proof of existence of International Transaction —Adjustment made in respect of advertising marketing and promotion of sales expenses to be deleted -Expenses reimbursed matter remanded [ S.92CA ]

Tribunal held that  the royalty was paid for  basket of  services . accordingly adjustment is held to be not justified . As regards  advertising, marketing and promotion of sales expenses  there being no proof of  existence of  International Transaction  adjustment made in  respect of advertising marketing and promotion of  sales expenses to be deleted . As regards expenses reimbursed matter remanded  to the AO for verification .( AY.2010-11, 2011-12)